Madhya Pradesh HC Orders Unfreezing of Bank Accounts Linked to Cyber Fraud

The Madhya Pradesh High Court has intervened to provide relief to a company whose bank account was frozen due to alleged cyber fraud, reinforcing the principle that legitimate business operations should not be indefinitely stalled by investigative delays. Justice Subodh Abhyankar directed the unfreezing of the petitioner’s account while ensuring that disputed amounts are secured in fixed deposits.

Following the precedent established in a similar matter, the Court addressed the grievance of the petitioner company which found its bank account lien-marked by IDFC FIRST BANK on the instructions of cyber cell authorities. The Bench observed the necessity of balancing investigative requirements with the rights of account holders to manage their lawful financial assets.

Judicial Scrutiny of Indefinite Account Freezing

The Court, in its reasoning, observed: "In such circumstances, this Court is inclined to dispose off this petition with a direction to the respondents/Bank to keep the disputed amount as informed to it by the crime agencies in fixed deposits, which shall be allowed to be liquidated only after the orders are passed by the competent Judicial Magistrate within three months’ time as it is expected from the Police agency to proceed in accordance with law under the relevant provisions of the BNSS or any other law on which it is relying upon, failing which the amount so kept in FD may also be allowed to be withdrawn by the petitioner under intimation to the Police agency."

Background: The Dispute and Legal Rationale

The petitioner, Dekain Perfect Tech Ksolution Private Limited, approached the Court under Article 226 of the Constitution of India after its account with IDFC FIRST BANK was frozen. The petitioner sought the removal of the lien and an order to prevent the bank from hindering lawful operations. It was argued that the case was squarely covered by the decision in Malcolm Murayis & Ors. Vs. State Bank of India and Others ( "W.P. No.1100 of 2024 dated 26.04.2024": 2024 CaseBase(MP) 20473).

In the relied-upon Malcolm Murayis & Ors. Vs. State Bank of India and Others ( "W.P. No.1100 of 2024 dated 26.04.2024": 2024 CaseBase(MP) 20473), the Court had dealt with accounts frozen at the behest of various cyber crime cells. That case highlighted a lack of communication from investigating agencies and a failure to comply with procedural requirements under Section 102 of the Cr.P.C.. Adopting the same logic, the Court noted that while disputed amounts potentially linked to cyber crimes must be protected, the entire account should not remain inaccessible. By directing the conversion of disputed sums into fixed deposits, the Court provided a mechanism where the investigation could continue under the BNSS or Cr.P.C. while allowing the petitioner to regain access to their account. The petition was disposed of with these specific protections.

Case Details:
Case No.: WRIT PETITION No. 18579 of 2026
NeutralCitation: 2026:MPHC-IND:16111
Case Title: DEKAIN PERFECT TECH KSOLUTION PRIVATE LIMITED THRUOGH ITS DIRECTOR SANJAY SHARMA Versus IDFC FIRST BANK AND OTHERS
Appearances:
For the Petitioner(s): Shri Harshwardhan Sharma - Advocate
For the Respondent(s): Shri Tejas Vyas - Panel Lawyer

Source: 2026 CaseBase(MP) 50